JOHN ELIAS BALDAC'CI 

GOVERNOR 

DAVID P . LITTELL 

COMMISSIONER 

MEMORANDUM 

TO : Board of Environmental Protection 

FROM: Deb Avalone-King, Bureau of Air Quality 

DATE : March 18, 2010 

RE : Request to Adopt: Chapter 161 Graphic Arts - Lithography and Letterpress Printing 

Statutory and Regulatory Reference: 

A. Statutory authority . 

38 MRSA Section 585-A provides that the Board of Environmental Protection "may establish and 

amend regulations to implement ambient air quality standards and emission standards. These 

regulations shall be designed to achieve and maintain ambient air quality standards and emission 

standards within any region and prevent air pollution ." 

B. Specific legal mandates requiring adoption. 

Section 184 of the Clean Air Act requires states to implement or update reasonably available control 

technology (RACT) controls on all major VOC and NOx emission sources and on source categories 

covered by a Control Technique Guideline (CTG) document. EPA defines RACT as the lowest 

emission limit that a particular source is capable of meeting by the application of control technology 

that is reasonably available considering technological and economic feasibility. In September 2006, 

EPA published a CTG for offset lithography printing operations which recommended specific limits 

for chemicals and processes used in these operations. 

Location/Applicability_ : 

The proposed regulation will apply statewide. 

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STATE OF MAINE 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

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web sac' \-w.marnc.gov/dcp 
Memo to BEP 

March 18, 2010 

Page 2 of 2 

Description: 

Background: Many inks, fountain and cleaning solutions used in graphic arts contain volatile 

organic compounds (VOC), which are precursors to ground-level ozone formation . This regulation restricts the VOC emissions from offset lithography and letterpress printing operations. Under Section 184 of the Clean Air Act Amendments of 1990, the State must submit plans to control VOC emissions from all sources covered by a Control Technique Guideline (CTG) issued by US EPA. 

This regulation requires all sources within this category to determine their emission levels and 

implement reasonable options for keeping such emissions at a minimum, in a cost effective way that includes: control technology approaches, VOC and composite vapor pressure limits and standards for work practices . The rule provides a variety of approaches for managing VOC emissions and 

complying with the limits stipulated in the rule with flexibility for sources to implement the limits in the manner that is most suitable for their facility . 

Environmental Issues : 

Volatile organic compounds contribute to ground-level ozone formation or smog which aggravates 

respiratory ailments such as asthma, bronchitis, and emphysema. The presence of ozone impedes the 

breathing of even healthy people and exacerbates existing respiratory and heart health conditions. 

Epidemiologic studies show that long-term exposure to ozone causes premature aging of the lungs 

and decreases in lung capacity and function. Though children, the elderly and those with heart disease 

or respiratory problems like asthma and emphysema are at particular risk, about 20 percent of 

otherwise healthy adults are unusually sensitive to ozone's effects, experiencing symptoms like 

coughing, wheezing and pain when they breathe deeply in highly polluted areas. 

Significant Changes Were Addressed in Second Opportunity to Comment period: 

A number of comments were received as a result of the first comment period that have been 

incorporated into Chapter 161 including: 1) a clarification of the applicability threshold and related 

recordkeeping requirements; and 2) inclusion of BACT related alternatives for compliance test 

methodology, recordkeeping requirements and oxidizer operating system parameters . At that point 

the Board directed the Department to repost the rule for a.second comment period to allow an 

additional opportunity for public comment on those significant modifications . 

Departmental Recommendation : 

The Bureau now seeks approval of the proposed new regulation, Chapter 161 ; with amendments 

as outlined in the Final Rule and Supplemental Basis Statement. 

Estimated Time of Presentation : 

20 minutes